By John Schmoker, Compliance Testing Services Project Manager
I was recently speaking with a fellow NERC enthusiast and it was mentioned that the NERC world appears to be slowing down. “From a Generator Owner/Operator standpoint it doesn’t appear there’s much in the pipeline.” he said. I responded with a warm-hearted gest about the unrelenting nature of regulation and pointed him toward NERC’s “Reliability Standards Under Development” page. A quick glance through the site makes it clear that continued NERC compliance is not a foregone conclusion.
Tracking changes to the NERC Reliability Standards can be a full-time occupation or an awkwardly satisfying hobby. I make no admission as to which applies to me. As members of the power industry, it’s our responsibility to understand, plan for, and implement revisions to the NERC requirements.
According to NERC’s website, there are currently 18 open Standard development projects in various stages of completion. The proposed changes would affect nearly 40 Standards, which apply to the full range of functional registrations. Topics are similarly wide-ranging and include:
- Changes to the system operating limit development process (FAC-010/011/014),
- Management of primary frequency response (BAL-003),
- Changes to dynamic modeling requirements (MOD-026/027),
- Revisions to real and reactive power verification (MOD-025)
- Changes to coordination of voltage regulating protection and controls (PRC-019)
- Establishment of a new cold weather preparedness standard (EOP-011),
- Modifications to disturbance recording requirements (PRC-002),
- Revisions to protection system maintenance requirements (PRC-005),
- Multiple revisions to the Critical Infrastructure Protection (CIP) Standards, among others.
While it may be unwise to finalize compliance plans prior to formal FERC approval, it is always beneficial to keep abreast of changes that may apply to your functional registration(s). For NAES, a good example would be the proposed changes to the Protection and Control (PRC), Modelling (MOD), and CIP Standards. As many of you know, NAES operates a substantial generation fleet spanning all six NERC Regions. Costs associated with engineering, testing, and modeling can be considerable. These coupled with the need for additional outages, fuel procurement, and possible reductions in production greatly concern the owners of the facilities we operate. Advanced planning is key for these types of expenses and a sharp eye toward Standard’s development can greatly improve an entity’s future position.
In addition to the technical Standards, the continued evolution of CIP requirements is also incredibly important from both a financial and security standpoint. We don’t have the bandwidth to debate the merits or shortcomings of the CIP Standards here, but we are seeing more and more entities transitioning from a strict adherence to the CIP requirements to a more holistic cyber security approach. This approach could provide somewhat of a buffer from the ever-changing CIP compliance environment, but it does not prevent the need for continued diligence from a Standard’s development perspective.
While it may seem to some that the NERC Standards have found a steady state, it may be more apt to describe them as “maturing”. No matter how you look at it, it’s clear there are benefits to keeping up with Standard’s development.